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The Second Circuit Court of Appeals affirmed the convictions of an attorney for "one count of corruptly obstructing a judicial proceeding, in violation of 18 U.S.C. § 1512(c)(2), one count of forging a judge’s signature, in violation of 18 U.S.C. § 505, and one count of making a false statement to a federal officer, in violation of 18 U.S.C. § 1001(a)(2), in connection with his fabrication of a court order."

The appeal presented five arguments:

"(1) that there was insufficient evidence to establish that his conduct would have the 'natural and probable effect' of obstructing the lawsuit, such that a conviction for obstruction of justice under 18 U.S.C. § 1512(c)(2) was inappropriate; (2) that the jury should have been instructed to find, and evidence was required to establish, an intent to defraud under 18 U.S.C. § 505; (3) that it was error to permit the government to crossexamine Reich’s character witness by asking about an allegedly 'private' unauthorized change to his law partner’s life insurance policy; (4) that there was insufficient evidence to establish that he made a false statement to a government agent; and (5) that the district court improperly applied a 'special skills enhancement' in calculating Reich’s sentence under the United States Sentencing Guidelines Manual ('U.S.S.G.' or 'Guidelines')."